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Carrie Buck (1906–1983)

Carrie Buck was the
first person involuntarily sterilized under Virginia's eugenics laws. In 1920 her
mother was diagnosed as feebleminded—a diagnosis based less on a medical finding than
on the doctors' perception of her sexual behavior—and committed to the Virginia State
Colony for Epileptics and Feeble-Minded in Lynchburg. Buck moved in with a foster family and in
1923 became pregnant, claiming that the foster family's nephew raped her. The
teenager was similarly deemed epileptic and feebleminded and placed at the colony
after she gave birth in 1924. The colony's superintendent decided to use Buck as a
test case for the state's new sterilization law. In Buck v. Bell (1927), the U.S. Supreme Court ruled that Virginia's law was constitutional
and that Buck should be sterilized. Her sterilization was the first of approximately
8,300 performed under state law between 1927 and 1972. After her release from the
colony Buck, in sharp contrast to her diagnosis, lived an active life until her death
in 1983. MORE...

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Carrie Elizabeth Buck was born in Charlottesville on
July 2, 1906, the daughter of Frank W. Buck, a tinner, and Emma A. Harlow Buck. Her
father died when she was very young. In April 1920 her mother was committed to the
Virginia State Colony for Epileptics and Feeble-Minded in Lynchburg with a diagnosis
of feeblemindedness, a vague term that was less a medical finding than a reflection
of the examiners' distaste for her sexual behavior. Carrie Buck had been removed from
her mother's care when she was three and placed with a foster family. She attended
local schools, where her records indicate normal progress each year, but before she
completed sixth grade her foster family withdrew her to perform housework for
them.

In 1923 Carrie Buck became pregnant, by her account as the result of rape committed
by a nephew of the foster family with whom she had lived for almost fourteen years.
Believing that the pregnancy was evidence of promiscuity and thus of
feeblemindedness, the foster family sought to have her committed, like her mother, to
the Virginia State Colony for Epileptics and Feeble-Minded. At a hearing on January
23, 1924, Buck was adjudged epileptic and feebleminded. Following the birth on March
28, 1924, of an illegitimate daughter, Vivian Alice Elaine Buck, Buck entered the
colony in Lynchburg on June 4. Her former foster family took her infant daughter into
their home and gave her their name.

Shortly after Buck's commitment, Albert
S. Priddy, superintendent and physician at the colony, selected her to be the
subject of the test case for the constitutionality of Virginia's recently enacted
involuntary sterilization statute. This law provided that the state could sterilize
anyone found to be incompetent because of alcoholism, epilepsy, feeblemindedness,
insanity, or other factors. Behind the law was the eugenic assumption that these
traits were hereditary and that sexual sterilization could thus prevent their
transmission. Uncertain that the new law could withstand a constitutional challenge,
the framers and supporters of the law arranged to test it in court. They chose Buck
in the belief that she had inherited her feeblemindedness from her mother and that
her daughter showed signs of slow mental development as well.

The litigation went to circuit and appeals courts in Virginia, where the judges
approved Buck's sterilization. Eventually styled Buck v. Bell (referring to John H. Bell, the superintendent of the
Virginia colony following Priddy's death in 1925), the case went on to the United
States Supreme Court in April 1927. On May 2 of that year the court ruled that
Virginia's law was constitutional and that Buck should be sterilized. In the majority
opinion Justice Oliver Wendell Holmes enthusiastically declared that the "principle
that sustains compulsory vaccination is broad enough to cover cutting the Fallopian
tubes." In an oft-quoted phrase, he concluded that "three generations of imbeciles
are enough." Consequently, Buck and approximately 8,300 other Virginians, including
her younger half sister, were sterilized under the state law between 1927 and
1972.

After being surgically
sterilized on October 19, 1927, and released from the Virginia colony to work for a
family in Bland County, Buck
married William D. Eagle, a widowed carpenter, on May 14, 1932. A quarter-century
after his death on July 23, 1941, she married Charles A. Detamore, of Front
Royal, on April 25, 1965. Friends, relatives, and professionals who knew her later in
life deny the accuracy of her diagnosis as mentally retarded. She was independent and
a helpful person to others for most of her life. Carrie Buck Eagle Detamore
died on January 28, 1983, in a nursing home in Waynesboro and was buried in Oakwood Cemetery in
Charlottesville. Vivian Dobbs, the daughter from whom she was separated shortly after
giving birth, is buried on an adjacent hillside. Belying Justice Holmes's famous
opinion, Dobbs was an honor student when she died of enterocolitis on July 3, 1932,
at age eight. The practice of involuntary sterilization did not cease in Virginia
institutions until 1972, and the enabling act remained on the books until April
1974.

Time Line

July 2, 1906
- Carrie Buck is born in Charlottesville, the daughter of Frank W. Buck, a tinner, and Emma Adeline Harlowe Buck.

1910
- At age three, Carrie Buck is taken from the care of her mother, Emma A. Harlowe Buck, and placed with foster parents, John and Alice Dobbs.

April 1920
- Authorities deem Emma Buck a "low grade moron" and promiscuous for having a child out of wedlock and commit her to the Virginia State Colony for Epileptics and Feeble-Minded in Madison Heights, near Lynchburg.

January 23, 1924
- Responding to a petition by her foster parents, a court in Charlottesville adjudges the pregnant seventeen-year-old Carrie Buck to be feebleminded.

March 20, 1924
- The General Assembly passes a bill that allows for the state-enforced sterilization of those deemed genetically unfit for procreation.

March 28, 1924
- Vivian Alice Elaine Buck, the daughter of Carrie Buck, is born in Charlottesville.

June 4, 1924
- Having been adjudged feebleminded and committed by a Charlottesville court, Carrie Buck arrives at the Virginia State Colony for Epileptics and Feeble-Minded in Madison Heights, near Lynchburg. Her mother, Emma Buck, is also an inmate there.

November 19, 1924
- Judge Bennett T. Gordon, of the Amherst County Circuit Court, hears arguments in the case of Buck v. Priddy, appealing the order to sterilize Carrie Buck.

April 22, 1927
- The U.S. Supreme Court hears oral arguments in the case of Buck v. Bell, appealing an order to sterilize Carrie Buck.

May 2, 1927
- In Buck v. Bell, the U.S. Supreme Court upholds a Virginia order to sterilize Carrie Buck.

October 19, 1927
- Dr. John H. Bell performs the operation to sterilize Carrie Buck several months after the U.S. Supreme Court upholds, in Buck v. Bell, the
constitutionality of a Virginia law allowing state-enforced sterilization.

April 1931
- Vivian Dobbs, the daughter of Carrie Buck, is placed on the honor roll at the Venable Public Elementary School in Charlottesville.